BUSINESS CONDUCT GUIDELINES · Our Business Conduct Guidelines and your commitment Working Together...

BUSINESS CONDUCT GUIDELINES

W.W. GRAINGER, INC. AND SUBSIDIARIES | BUSINESS CONDUCT GUIDELINES

“ Each day we come together with our diverse experiences and perspectives to help keep people around the world working and safe. While we may have different jobs, we expect team members to do the right thing in all situations.” – D.G. Macpherson


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TO ALL TEAM MEMBERS:

Our Grainger team is more than 24,000 people strong. Each day we come together with

our diverse experiences and perspectives to help keep people around the world working

and safe. While we may have different jobs, we expect team members to do the right

thing in all situations. This means we are all committed to achieving our mission with

the highest ethics and integrity in and outside of our industry. It also means that we can

create value for our customers, gain share versus competitors and achieve our financial

goals while making the right choices. In fact, doing the right thing ensures that our

success is sustainable. Our commitment to doing our jobs with integrity is unwavering.

Our Business Conduct Guidelines help each of us, no matter where we work. Each

year, we each pledge to read, understand and stay true to the Guidelines – it’s one of

the most important things we can do to strengthen our culture and our company. While

no guideline can cover every situation we face, we are charged with making sound,

principled decisions, and we’re expected to seek out support when we need help.

Thank you for committing to our Guidelines and for upholding the high standards that

have shaped our company for nearly 100 years.

D.G. Macpherson

Chairman of the Board and Chief Executive Officer

CONTENTS

Our Business Conduct Guidelines and your commitment

Working Together Treating each other with respect and keeping each other, our customers, suppliers and visitors safe

Customer and business partners Integrity in all we do

Our commitment to shareholders Ensuring financial practices are sound

When you call the Hotline

Have a question or concern?

D.G. Macpherson

“ Our commitment to doing our jobs with integrity is unwavering.”



Operating with the highest standards of ethics and integrity defines Grainger’s strong

culture and who we are as a company. Each day, team members strengthen our culture

by maintaining our good reputation, complying with all laws and following ethical

practices. The Business Conduct Guidelines define our shared expectations of how we

work together, serve customers and business partners, and honor our commitments to

shareholders everywhere we do business globally. They’re essential to maintaining and

strengthening our healthy workplace.

Each year, all team members, officers and members of our Board of Directors are

required, as a condition of employment, to certify that they read, understand and comply

with our Business Conduct Guidelines. This includes following the Guidelines, supporting

others to do so, and speaking up when there is a suspected violation. All reports are

taken seriously, investigated thoroughly and addressed promptly. Those who violate the

guidelines may face serious repercussions, including termination from the company.

There are many resources ready to help you understand the guidelines and to report

any concerns. All of the following are available so you can choose those that best fit

the situation:

• Your supervisor or manager

• Your Human Resources representative

• The Legal Department

• Environmental Health and Safety

• Security and Loss Prevention

• Anonymous reporting through the company’s toll-free and web-based hotlines.

These hotlines are operated by an outside professional resource:

– U.S. Number: 1(888) 873-3731

– Global phone numbers are listed at www.grainger.ethicspoint.com

– Report through the web portal and globally: www.grainger.ethicspoint.com

Grainger does not tolerate retaliation against any team member for making an inquiry,

initiating a complaint, or participating in an investigation. No one who, in good faith,

raises an issue or concern will be subject to retaliation. We will maintain anonymity to

the extent permitted by law. Any team member who believes that he/she is the subject

of such retaliation is expected to report this immediately to the Human Resources

Department or the Legal Department.

People leaders play a pivotal role in reinforcing our ethical and inclusive culture

by supporting the Business Conduct Guidelines. Leaders must hear team member

concerns, maintain confidentiality and take appropriate action with their Human

Resources partner.

OUR BUSINESS CONDUCT GUIDELINES AND YOUR COMMITMENT

Why are all team members required to certify the Business Conduct Guidelines every year?

The business environment is always changing and it’s important that all team members understand our way of working no matter external influences.

What do I do if I get a request from a fellow team member in a different part of the world that I believe violates the Business Conduct Guidelines?

The Business Conduct Guidelines define how we are all expected to work. Discuss your concerns with your manager and escalate as needed.

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REAL LIFEBCG

REAL LIFEBCG

POLICIES AND GUIDELINES FOR TEAM MEMBERS

Our company has a number of

policies to support our Business

Conduct Guidelines. A complete list

of company policies is available on

the company intranet.


DIVERSITY AND INCLUSION Having a workplace where we can openly share ideas to ensure we’re

doing what’s best for our customers and our fellow team members is

critical to our success. Every team member plays an important role in

protecting Grainger’s healthy culture that respectfully challenges ideas

and encourages and values different experiences. We are committed to

fostering a culture of inclusion and diversity where all team members

feel safe, valued and encouraged to voice their opinions, regardless of

sex, gender, race, color, religion, national origin, age, disability, veteran

status, sexual orientation, gender expression or experiences. We expect

every team member to treat each other with dignity and respect.

WORKING TOGETHER TREATING EACH OTHER WITH RESPECT AND KEEPING EACH OTHER, OUR CUSTOMERS, SUPPLIERS AND VISITORS SAFE


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WORKING TOGETHER CUSTOM

ERS AND BUSINESS PARTNERS OUR COMM

ITMENT TO SHAREHOLDERS


WORKPLACE BEHAVIOR – FREEDOM FROM HARASSMENT AND DISCRIMINATION We are all responsible for creating and maintaining a productive work

environment free from any kind of inappropriate conduct, harassment or

bullying. We expect each team member to treat each other with respect

and we do not tolerate harassment or discrimination in any form.

Harassment and discrimination can take many forms, including conduct

that can lead to interfering with our work, diminishing a team member’s

dignity or creating an intimidating, hostile or offensive work environment.

Any type of harassment, including physical, sexual, verbal or other, is

prohibited and can result in disciplinary actions up to and including

termination, subject to applicable law.

WORKPLACE SAFETY Our company is committed to providing a workplace that is safe and

secure. Each of us helps meet that commitment by complying with

relevant health and safety laws, and company policies that are designed

to maintain a safe workplace. We have a zero-tolerance policy when it

comes to acts or threats of violence. Be alert on what is going on around

you, observe good security practices and speak up about any threats of

potential violence.

SAFE BEHAVIOR

All team members have the responsibility to perform their jobs in a safe

manner, and to follow company policies, business unit procedures and

laws relevant for the environmental, health and safety of the business.

Any condition or work practice that may result in personal injury and

illness, and/or damage to property, must to be reported immediately

to appropriate management.

SUBSTANCE ABUSE – ALCOHOL AND DRUGS

Team members are expected to perform their jobs alcohol and

drug free. Being in possession of or working under the influence of

drugs or alcohol can create a safety hazard and affect your judgment

and performance.

We recognize that on occasion, alcohol may be provided at a

company-sponsored event or with a business meal. You should ensure

that your consumption of alcohol does not impair your performance

and judgment.

Q Yuri needs to promote a member of his team to replace one who just retired. He thinks that, since David is 50 years old and nearing retirement age and Elena is only 35 years old and may stay with the company for many years, it would be wise to promote Elena. After all, the company will invest in training and he wants this investment to be used wisely. Is this a good decision?

A No. Yuri is making this decision in part on the basis of age. This discriminatory practice is illegal, contrary to our values and never acceptable. As a leader, Yuri is modeling the wrong behavior and is putting his position and the company at risk. Yuri needs to make decisions regarding team member promotion based on individual merits and qualifications.

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My doctor has prescribed marijuana to treat my medical condition. Can I bring my medical marijuana to work?

Consult your local policy or speak with your Human Resources representative.

REAL LIFEBCG

WEAPONS

Weapons of any kind or nature are prohibited in any company facility

or at any company- sponsored event, and they may not be brought

into any customer or vendor’s facility or place of business.

OUR ENVIRONMENTWe work to improve our environmental performance across our entire

value chain from our suppliers through our operations and to our

customers. Team members are expected to be good stewards of the

environment. More information about how team members can help

the company’s sustainability efforts can be found at Graingercsr.com.

POLITICAL ACTIVITIES We respect and encourage all team members as individuals to

engage in the political process. However, all political activities

must be kept separate from your work responsibilities. No company

assets can be used to support your personal political activities or to

make any contributions to political parties, candidates or campaigns.

If you engage in political activities, do this on your own time and

use your own resources to avoid any impression that you are

representing Grainger or acting on the company’s behalf.

Q Jake confidentially reports a concern to his supervisor related to safety compliance on his team. In the weeks that follow, he notices that his manager is overly critical and distant with him. Recently, he discovers that he will be reassigned to another shift, which is very difficult for Jake because of family obligations. What should Jake do?

A Jake did the right thing by reporting the safety issue. If Jake believes he is experiencing retaliation for reporting his concern, he should immediately contact Human Resources, Grainger legal counsel, his distribution center leader or company hotline. The company will not tolerate retaliation against any team member who seeks advice, raises a concern, or reports suspected misconduct in good faith. We must strive to continue to create and maintain a culture that encourages and supports this behavior.

I often wear company-logo gear after work. What are my responsibilities?

We’ll keep it simple. If you’re wearing company-logo gear after hours, act in the same way you would at work. If you don’t plan to act that way, don’t wear the gear. Additionally, do not wear Grainger gear to any political rally or event.

REAL LIFEBCG




https://www.graingercsr.com


CUSTOMERS AND BUSINESS PARTNERS INTEGRITY IN ALL WE DO

BE HONEST AND FAIR IN ALL BUSINESS DEALINGS We are all required to be honest and fair in dealings with our

customers, suppliers, fellow team members, the company, competitors

and other members of the business community. This means ensuring

that our behavior reflects our company’s standards for ethics and

integrity and that our actions are in the company’s interests.

AVOID CONFLICTS OF INTEREST All team members are expected to always make decisions based

on sound business judgment and in the best interest of Grainger.

A conflict of interest can exist when a personal interest, relationship

or opportunity for personal gain interferes with your duties and

responsibilities to the company. This includes offering gifts that

compromise the business judgment of others or accepting gifts

that can influence your professional objectivity. Simply put, you

must not use your position or the company for your own personal

benefit. Here are some questions to ask:

• Does it interfere with the work I do for the company?

• Am I using company resources, relationships or assets for my

own personal gain?

• Could it appear to be a conflict of interest to someone else?

• Does it compete with the company’s interests?

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ANTI-CORRUPTION, IMPROPER PAYMENTS AND BRIBESGrainger is committed to honest and fair business practices that are

consistent with the highest ethical and legal standards. Team members

are prohibited from offering, providing, receiving or accepting bribes

or anything of value to gain business, establish business relationships,

influence decisions in the company’s favor or for any other reason.

Team members must also avoid customary practices that could create

the appearance of a bribe. The simple rule is do not offer, pay, receive

or accept a bribe to anyone, anytime, anywhere.

Our company is committed to compliance with all applicable laws and

regulations including but not limited to, the U.S. Foreign Corrupt Practice

Act (“FCPA”), the U.K. Bribery Act, and other laws and regulations that

relate to corruption, bribery, money laundering, or support for terrorism.

All team members involved in international transactions must consult

the trade compliance policies for proper guidance on all import and

export transactions and follow the international trade and export control

laws. Country prohibitions, boycotts and embargoes, denied parties and

restricted goods requirements must be followed before engaging in

international transactions.

COMPETITION AND ANTITRUSTWe do not take any action that would prevent or inhibit fair and open

competition. Treating our customers, suppliers and competitors fairly

is the way Grainger does business. To ensure that we comply with

fair competition laws that promote competition in a free market:

• Do not discuss Grainger’s business with competitors including:

– Economic terms

– Pricing

– Market plans

• Do not enter agreements with competitors that include:

– Arrangements to fix prices

– Arrangements to fix territories or divide customers

– Arrangements to prevent other competitors from entering

the market

• Do not make false or misleading statements or comments

about our competitors or their products or services.

• Make sure all statements are accurate and complete.

What if a bribe or facilitating payment seems like the only option?

No matter the country or business, a bribe is never an option at Grainger. If you believe a bribe is necessary or someone pressures you to bribe, then you must speak up. The company will involve the right people to find the right way forward. We can often solve problems by contacting higher levels of government or business associations. We will pass on any business opportunities that would require a bribe.

Q Sue overhears a team member boasting about receiving reimbursement from the company for her recent personal expenses. Later, Sue shares her concern privately with her manager Karen. Karen listens carefully and thanks Sue for her courage in speaking up. What should Karen do next?

A After assuring Sue that her concern will be addressed, Karen should escalate this allegation of fraudulent conduct to the Security department for investigation. Until the facts are understood, Karen should maintain a high level of confidentiality. Even though she may not be able to provide details on the investigation, Karen should remain in contact with Sue to assure her that she is engaged in the process. By being fair, objective, and responsive to Sue’s concern, Karen can create a trusting environment where Sue and others will feel safe to voice concerns before they become larger problems.

REAL LIFEBCG

How do we define Gifts and Entertainment?

Gifts and entertainment can mean many different things, from logo pens and apparel to sports tickets and dinners. The main point is that gifts and entertainment should not be used to influence the objectivity of the people with whom we do business or be allowed to influence your professional objectivity. Always use your good judgment and avoid anything that is lavish or not customary or that will embarrass your colleagues or the company.

REAL LIFEBCG





CONDUCTING BUSINESS WITH GOVERNMENT, HEALTHCARE AND EDUCATION-BASED CUSTOMERS Grainger values its federal, state, local government, healthcare and

education-based customers. Serving these customers is a public

trust and involves a variety of procurement and ethics laws and

regulations. Our company conducts business with these customers

in strict compliance with these requirements. In addition, we will

never take any action that would create even the appearance of a

conflict of interest.

Our company strictly prohibits giving any gifts or gratuities to any

government, healthcare or education customer. If you serve any of

these customers, you are expected to know and follow all procurement

and ethics laws and regulations in all countries where we operate.

In addition, all U.S. team members who work with these customers

are expected to know and follow Grainger’s Code of Ethics for Doing

Business with Government, Healthcare and Education-based Customers.

Any questions or concerns should be raised with the Legal Department.

DATA PRIVACY, CONFIDENTIAL INFORMATION AND TRADE SECRETSSafeguarding Confidential Material, Personal Information

and Trade Secrets

Grainger recognizes the importance of team member, customer and

supplier personally identifiable information (PI I) that we collect during

normal business activities. PI I helps us fulfill orders, provide benefits,

and better serve our customers, team members and others. We are

committed to taking steps to protect PI I from unauthorized access,

use or disclosure by following globally recognized privacy principles

and building privacy and data protection standards into our systems

and processes. You play a key role in keeping this data safe and

Grainger provides training for all team members involved in accessing

or managing PII. Grainger’s Privacy and Information Security and

Protection policies, as well as our Privacy Principles, provide the

information you need to collect, use, share, store and destroy PII

in an appropriate manner.

Q Jesse is working with procurement to hire a new printer. When she arrives at work on Tuesday, she finds an elaborate gift basket from one of the vendors in the running. It includes all her favorite things including chocolates, wine and tickets to a sporting event. What should she do?

A Jesse should alert the procurement team and work with them to return the gift basket and tickets. The procurement team should alert the vendor that such gifts are not acceptable.

What is bribery?

Bribery occurs when a person offers something of value to another person in order to get what they want without following the prescribed rules and regulations. Grainger has no tolerance for bribery of any kind.

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What is intellectual property?

Intellectual property is our innovative ideas and works that are the result of creativity—such as inventions, publications and writings, images, symbols, logos, brand names and tag lines. Our company’s intellectual property is one of our most valuable assets, and we substantially invest in its development. We protect our intellectual property by obtaining patent, trademark, or trade secret protection, and by taking precautions to prevent inappropriate disclosure, use, or loss of such information. We enforce our rights and we respect the intellectual property rights of others.

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We all have an obligation to ensure that the company’s confidential

information and trade secrets are properly protected. Team members

must maintain the security and secrecy of the information entrusted

to them by the company, its customers, suppliers or others. Confidential

information and trade secrets include all non-public information

that, if disclosed, might be of use to competitors, or the disclosure

of which might be harmful to the company, including but not limited

to pricing strategies, corporate strategic and marketing plans, customer

information and lists, team member records, supplier and logistics

information, databases, software and all proprietary information

and data.

All team members are required to protect all company information

and assets. Precautions include:

• Follow company processes and only access systems for which

you are authorized to ensure you are not inadvertently putting

the company at risk.

• Do not discuss company business in public places and where

you could be overheard.

• Ensure you are always in personal possession of your

company-issued electronic devices and that your passwords are

complex, changed frequently, and limited to work systems.

• Do not transfer Grainger information from protected company

systems to USB or portable hard drives or to personal online file

sharing services.

• Immediately report any loss or compromise of company systems

or confidential information.

Contact the Privacy Office, Information Security, or Legal department

if you have questions regarding disclosure of information.

Q Lauren is a new team member who is really impressed with how her leader, Dave, consistently achieves goal. One day she sees him do something with a big customer that seems contrary to our Business Conduct Guidelines and she asks Dave about it. His response is “it’s not illegal.” What should Lauren do?

A Lauren should share her concerns with her Human Resources representative, the Legal department or use the company hotline. All team members are required to follow the Business Conduct Guidelines. Additionally, wrongdoing is not always a question between right and wrong. It can also be a choice between doing what is right or doing what is easy. People who rationalize their behavior often use phrases such as those below. These are good indicators of a wrong decision.

• I deserve this

• This is the only way I can achieve my goal

• Everyone else is doing it

• It’s not illegal

• I’m not hurting anyone

• It’s a trick of the trade

• This is how we do things here

• This is how it’s done at other companies

• It’s just for this one time

What is personal identifiable information?

Personal identifiable information or PII is any information that can be used to identify a specific individual such as a person’s name, address, email, date of birth, driver’s license number, financial account numbers, passport or other government identification number. While one item alone may not be damaging, hackers seek several pieces of data to compose a complete picture.

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EXTERNAL COMMUNICATIONS AND SOCIAL MEDIA

Since its founding, Grainger has worked to build a strong and respected

reputation. To protect our reputation and ensure we are speaking

with one voice, all team members must be approved by Corporate

Communications and Public Affairs to speak on behalf of the company.

This includes media interviews, speaking engagements, social media

as well as authoring articles, videos or podcasts.

Team members are encouraged to share and repost public information

approved by the company on social media. We all have a responsibility

to be respectful and ensure our statements don’t negatively impact the

company. Helpful tips:

• Do not post proprietary or confidential information.

• While you are always welcome to engage in productive discussions

of employee-related topics such as the terms and conditions of

employment, or otherwise participating in activity protected by the

National Labor Relations Act or other employment and labor laws,

ensure posts that express your personal opinion are not used to

represent that of the company.

• Do not use social media or post anything that would harass,

intimidate or threaten another team member, their family or violate

the company’s Equal Employment Opportunity Policy, Workplace

Behavior Policy or Workplace Violence Prevention Policy.

• Refer to Grainger’s Social Media Policy and contact the

Communications and Public Affairs team with any questions.

If you become aware of an actual or potential conflict with our goal of

having integrity in all we do, you have the obligation to immediately

disclose it through one of our many reporting channels.

What do I do if I overhear something or see a post on social media that relates to a team member harming themselves or being harmed by others?

Immediately contact your supervisor as well as the Security team and your Human Resources representative.

Can I use social media to support our company?

You are encouraged to share Grainger-approved messages (via reposting, retweeting, sharing) from Grainger’s social media accounts (Facebook, Twitter, Careers Twitter, Instagram, LinkedIn) with your own personal networks. If you are interested in posting, be sure it doesn’t violate Grainger’s confidentiality, legal guidelines or your own privacy. Remember, if you’re online, you’re on the record. What you write is ultimately your responsibility. Some tips:

Be Cautious: If you’re unsure about something you would like to post, check with [email protected] for guidance. A good rule of thumb is if in doubt, don’t post. Topics that are always off limits include: legal matters, non-published financials and unreleased product or company information.

Be Respectful: Do nothing that could undermine your credibility or damage Grainger’s reputation. Do not criticize Grainger’s competitors, customers or suppliers.

Be Mindful of our Brand: Do not use the word “Grainger” or any company trademark as part of your screen name or user ID, page, group or site name. Do not use Grainger logos, images, brand names or trademarks without permission from Corporate Communications. Do not alter or modify any other Grainger intellectual property. For example: do not open a Twitter account using a name such as @JohnSmith-GraingerOklahoma.

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FINANCIAL RECORDS Accurate financial records are required to provide relevant, reliable

and timely information to support the company’s business decisions.

Accurate financial records also are critical for demonstrating the

company’s compliance with both internal and external reporting

requirements. All financial records must be complete, accurate,

up-to-date and managed through a robust system of internal

controls. This includes not only financial statements, but also such

data as sales and purchasing records, inventory management records,

business metrics, performance-related records, travel and expense

records and worktime reporting among many others.

TRADING STOCK

It is illegal to trade stock if you have “material non-public information”

or to share any of this information with others who may trade including

family, friends, colleagues, neighbors, among others. Insider or material,

non-public information can include:

• Non-public financial information

• Expectations of substantially higher or lower earnings

• Significant cybersecurity breach or incident

• Actual or threatened significant litigation or inquiry by a

governmental or regulatory authority

• New business model, markets or strategies

• Proposed business acquisitions, dispositions, joint ventures

or mergers

• Changes in key team members

The company prohibits anyone from trading in derivatives

(e.g. puts, calls, options) and engaging in short sales, or hedging

or monetizing transactions (e.g. collars, exchange funds) that are

linked to Grainger stock. If you are considering selling, purchasing

or exercising company stock or derivatives and have questions,

please contact the Legal Department.

OUR COMMITMENT TO SHAREHOLDERS ENSURING FINANCIAL PRACTICES ARE SOUND

When are team members restricted from trading stock?

Any time you have information that is not public. Good judgment and laws prevent using this information to buy or sell securities, or “tipping” others (your spouse, coworker, friend, broker, and so on) with that information. The Corporate Secretary group of the Legal Department is ready to help you understand insider trading and related topics and answer any questions you may have.

REAL LIFEBCG



ITMENT TO SHAREHOLDERS W.W. GRAINGER, INC. AND SUBSIDIARIES | BUSINESS CONDUCT GUIDELINES

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WHEN YOU CALL THE HOTLINEAt Grainger, your voice matters. There are many resources available to help you understand the guidelines and report concerns. When you contact our

anonymous hotline through the company’s toll-free and web-based hotlines (www.grainger.ethicspoint.com) here is what you can expect.

You call the Grainger Hotline to report an incident or concern.

Your call is answered by a third-party representative independent of Grainger who specializes in hotline calls.

The representative asks for details about the incident or concern, like parties involved, location, etc. You can choose to provide your name or remain anonymous and decline to provide answers to any questions. Please provide enough information so that your concern can be fully investigated.

The representative emails a report to the Grainger Hotline team and you receive a report ID number that you can use to check on the status of your report. If you have decided to remain anonymous, you will not be identified in the report and the report ID number will be the only way to receive information.

The Grainger Hotline team reviews the report and assigns it to a designated person whose role is to look into the information you shared. This person may need additional information. If the report is filed as anonymous, please check back to see if more information is needed. Five percent of cases stop here due to lack of information to continue investigation.

Grainger is committed to providing a thorough due diligence review of any incident or concern submitted, when enough information is available to complete a review. Prompt and appropriate action is taken, maintaining confidentiality to the best of the organization’s ability. Specific outcomes to an incident or concern will not be explicitly provided.

Grainger reviews and takes remedial action in a manner that is respectful, consistent and fair. You are expected to cooperate in any investigation and can

be confident that you will not experience any retaliation for raising a concern in good faith or for cooperating with an investigation.

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NOT SURE? There are many resources ready to help you understand the guidelines and to report any concerns. All of the following are available so you can choose those that best fit the situation:

Is it legal?

Does this comply withGrainger’s BusinessConduct Guidelines?

Does this reflectGrainger’s principles

and culture?

Could this adverselyaffect companystakeholders?

Would you feel concernedif this appeared in a

news headline?

Could this adverselyaffect Grainger if all

team members did it?

• Your supervisor or manager

• Your Human Resources representative

• The Legal Department

• Security and Loss Prevention

• Environmental Health and Safety Hotline

• Report through the web portal and globally: www.grainger.ethicspoint.com

• Anonymous, toll-free and web-based hotlines.

U.S.: 1 (888) 873-3731

Global phone numbers listed at www.grainger.ethicspoint.com

NO DO NOT DO IT. The action may have serious consequences.

YES

NOT SURE? Utilize the resources below.

MOVE FORWARD. The action appears appropriate.

YES

NO

DO NOT DO IT. The action may have serious consequences.

NOT SURE? Utilize the resources below.

MOVE FORWARD. The action appears appropriate.

HAVE A QUESTION OR CONCERN? Here is a helpful tool. The process below can help you think through a situation. As always, if you have a question, use your resources listed below.


www.grainger.ethicspoint.com

© 2019 W.W GRAINGER, INC. 9/19

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